Greg Lastowka died last night. I really can't find the words, if you can, feel free to comment below.
A few days ago, there was an interesting ruling in the Triple Town / Yeti Town game cloning case, a.k.a. Spry Fox, LLC v. Lolapps, Inc. Triple Town and Yeti Town are both casual puzzle apps where tile elements are assembled and evolve. Spry Fox had sought to license the game to the defendants, but the defendants pursued a cloning strategy instead. The litigation presents roughly the same sorts of legal issues as the current EA/Zynga dispute and the recent Tetris clone decision.
This particular case has been talked up pretty extensively in the blogosphere over the last year. For instance, James Grimmelmann had some thoughts about the early stages of the litigation and game cloning generally:
"if Triple Town flops on the iPhone because Yeti Town eats its lunch, at some point Dave and his colleagues won't be able to afford to spend their time writing games any more."
Eric Goldman weighed in yesterday on this new ruling, connecting it to the EA litigation:
"The Triple Town ruling suggests that Zynga probably can’t score a quick win."
Legal commentators in the blogosphere (e.g. Nic Suzor, Technollama, Rebecca Tushnet, Venkat & Eric) have already offered some initial thoughts on the Ninth Circuit decision in MDY v. Blizzard. Since I talked about the district court opinion in this case in Chapter 9 of my book, I thought I'd post a few reactions too.
This post is going to be a bit on the long side, but that's only because the issues raised on this appeal are a bit tricky, meaning that I feel the need to lay a little doctrinal groundwork before getting to my thoughts about the case.
Though there was an interesting tortious interference decision in the appeal, I'm going to focus on the two copyright issues that were decided by the Ninth Circuit, one involving a claim that users of MDY's Glider program breached World of Warcraft (WoW)'s software license and the other claiming that users of MDY's Glider program violated the Digital Millennium Copyright Act (DMCA)'s prohibitions on circumventing technological protection measures that limit access to copyrighted works. This second claim focused on the operation of Blizzard's Warden program, which monitors a player's computer to see if it is running any unauthorized software.
The appellate court essentially found in favor of MDY on the licensing issue, reversing the lower court, and in favor of Blizzard on the DMCA-Warden issue, affirming the lower court. That adds up to a win for Blizzard. That win could be reversed, in theory, if MDY pursues further appeals. An en banc review of the Ninth Circuit is possible and there's always the slim chance of getting the case reviewed by the United States Supreme Court.
The School of Communication and Information at Rutgers is planning a major conference to be held April 8-9, 2011. The conference will cover the cultural, business, legal, and artistic aspects of the videogame and virtual worlds industries -- pretty much everything practical and academic about gaming. If you'd like to spend a couple of days conversing with other folks who think seriously about gamers and the video game industry, please consider submitting to the Call for Papers, which can be found here: https://bit.ly/gbgcall (Deadline for 500-word abstract = Dec. 15th.)
For more information about the conference see this link: https://bit.ly/gamebehindgame
More details about the sorts of topics we're looking to explore below the fold:
So as promised, here's the book: https://bit.ly/virtualjustice
That link points to a 2.5 MB PDF that is licensed as Creative Commons Attribution Non-Commercial. I'm hoping to get a cleaner copy at some point soon--if I do, it will be posted at the same location. I got a MUCH better copy as of noon on 11/3/10 and it is now posted at the above link.
If you prefer wood pulp, this is the Amazon link: https://amzn.to/virtual-justice
According to Playspan, and reported by various outlets this week, 13% of internet users bought virtual goods last year, spending a little over $90 on average. (If this is accurate, it matches the percentage of voters who claim membership in the Tea Party, the percentage of CEOs who drove hybrids in 2007, and the percentage of teenagers who eat the recommended amount of fruits and vegetables.) Estimated global revenues from sales = over $10B.
In related news, 44M game passwords were reportedly stolen, presumably with the hopes of supplying a bit of that 13 percent, multi-billion dollar market.
The maker of Farmville and Mafia Wars has sued PlayerAuctions, the prominent virtual property trading site. The Complaint alleges copyright and trademark infringement, state unfair competition claims and intentional interference with contractual relations. Lots of interesting statements about "virtual property" and "virtual currency," but at this point, the majority of this Complaint is made out to allege standard copyright & trademark infringement.
Complaint below the fold...
Back in October, Mike & I & others mulled for a bit about Farmville and its place in the gaming/MMO sphere. Recently, a lot of other people have been mulling about Farmville too, in a crabbier sort of way. From various sources, it seems Farmville was the bête noire of GDC this year (see this Sauron reference), both envied (for numbers, revenues, and buzz) and despised (for various reasons, but it seems to me, at least in part, for not being anything remotely like Portal).
About two weeks ago, I told Ren that I'd write up a post about the Stern v. Sony decision, which was issued early last month. This is a case where a federal court essentially answered the title question of this post. The answer, at least according to this particular court, is "no."
Just a brief link & thought. One of the oldest uses of game simulations is strategic training. Tripp Robbins passed this Wired Article along, about how football players are learning new moves from playing Madden. Of course, to the extent we learn things by virtually doing, isn't this just a bit troubling as applied to Grand Theft Auto?
I still have not found time to see Avatar, but since I keep a running search query on avatars in the news, I have seen quite a bit of commentary about the film , including spoilers. One thing I have been wondering about, for obvious reasons, is exactly how much Avatar has to do with avatars. In particular, is this fantasy about new embodiment in a new society connected to a broader cultural moment, when World of Warcraft is now recognized as being a "mainstream video game" du jour?
Today, Ethan Gilsdorf, blogging at USA Today, explicitly states the thesis:
Box office conquered, Avatar also proves the culture has shifted. Part role-playing game come true and part special effects masterpiece, its hybrid gamer-geek pedigree is as glaring as the blue skin of the Na'vi race that director James Cameron brought to life on the imaginary planet Pandora. Cameron's movie — alongside the rise of Harry Potter, the return of Tolkien and Lord of the Rings, and the obsession with online games such as World of Warcraft — shows that fantasy is no longer a shunned or exotic side dish. The genre has become the main dish.
Gilsdorf suggest that the cultural drift toward the legitimation of escapist fantasy is a good thing, for a variety of reasons:
They give us hope in hopeless times. Indeed, when you read heroic stories such as Lord of the Rings or Harry Potter, you sense that if a mere hobbit can withstand evil, why not you?
Hope is good, I would say. Of course, there are some other readings of the movie, which aren't quite so positive about the messages it conveys.
So, I'm curious to hear about 2 things from those reading this:
1) To the extent that MMORPGs and escapist fantasies are becoming more mainstream now (are they?), what are the pros and cons of this trend? What positive and negative roles does the fantasy genre play in society?
2) Avatar is certainly in the sci-fi/fantasy/escapism genre, but exactly how much is Avatar, the movie, really an expression of "gamer culture"? (Points for WoW reference spotting and links.)
(this is posted on behalf of Ashley Funkhouser - greglas)
Dear Terra Nova readers,
I am an undergraduate researcher at Trinity University who is part of the Worldplay Research Initiative. Our collaborative research project explores transnational communication in virtual worlds. This project is connected to a course taught by former Terra Nova contributor Aaron Delwiche.
Sort of apropos of Ted's post, take a look at this short essay in The Guardian: "To come out as a gamer is still to risk looking a social n00b: Even with sympathetic friends, we still speak low when we speak games."
This certainly is not true everywhere, and certainly is not true among communities of gamers. We don't tend to speak low on this blog about games, and there are plenty of gaming blogs out there. So I'm curious as to how this maps onto your personal social perceptions. In what particular circles do you "speak low when you speak games"? Work? Family? School? Where isn't it cool to "come out" as a gamer?
But let's put it in perspective. In three months the number one social game on Facebook has gone from zero to over 50 million players. Not registrations, but actual unique monthly players (about 20 million daily uniques).
So, yesterday, USA Today noted the same. Zynga's Farmville is at 56M:
Alas, because I have way too much to get done, this has to be just a short post. But this recent post from New World Notes caught my eye -- Xstreet, which is a sort of Second Life virtual eBay, has issued some very interesting guidelines (see here, here) about the rules of Second Life commerce, at least such commerce as is listed on Xstreet.
Dave Myers, a long-time games researcher and commenter here at TN, received some media coverage yesterday for his tale of Twixt, prompting 132 comments and counting. Scott Jennings has some snarky comments on his blog and thinks this is all about a game design flaw.
Personally, I find these kinds of social "flaws" and how they are fixed pretty interesting. In my book, I'm using the story of Twixt to make a simple point that most readers of this blog will already appreciate. The rules that are enforced in MMOGs, like the rules enforced in any society, are not limited to the formal rules set forth in writing or coded into the software. Users decide for themselves how games should be played.
Update: Dave responds to all the attention here. A few lines I find particularly interesting in relation to what Richard says below and the question of EULAs:
Most surprisingly of all (maybe only to me), game designers themselves seem no longer interested in their rules. They seem to focus increasingly less on game rules and increasingly more on game rulers. Rulers don’t like the game rules? No problem. Eliminate those rules.
Like night follows day, it follows that if "virtual" currency X has a "real" exchange value of $Y, and the virtual world mechanics permit or even encourage player A to rob or swindle player B of a substantial amount of X, then we're going to have this sort of virtual crime.
Q: When will it be old news? A: Hopefully, sometime in 2012, after my book comes out.
Also, Reuters (or CBC?) doesn't seem to understand the recent Chinese regulations very well.
Update: Apparently, a blog on the New York Times thinks this is new stuff.
Jonathan Kinkley, who has just completed his Masters Thesis in Art History at University of Illinois at Chicago, ask if we could share his research. We're always happy to link to new work on virtual worlds.
The full paper is available here:
His thesis analyzes the visual culture of Second Life and explores the complex spaces that online social networks create. Jonathan explains:
In Second Life's Caledon, we get a glimpse what an online social formation looks like. It is a society based entirely on shared interests - a themed community built of a patchwork quilt of Victorian-era iconography. Elsewhere in SL, artists like Cao Fei (SL avatar China Tracy) are fascinated with this idea of creating a sense of place out of virtual space. Her RMB city isn't about China, it's about China-ness - an amalgam of all the icons, stereotypes, and archetypes past and present of China. This paper is about the types of spaces in SL and how and why they are created out of the iconography of visual culture.
State of Play 6 (2009) is up and running at New York Law School. Yesterday was the grad student symposium and today is the first day of the two-day main event. Dan is kicking things off at the podium and Raph Koster will be giving the keynote next on metaplace. Feel free to post whatever conference-related in the comment. If I can, I'll do some live-blogging in the comments here.
This is pretty much an open thread for comments/reactions about SOE's Free Realms.
I haven't had time to play with it yet, but there sure has been buzz and the rarely impressed Scott Jennings even seems to be sort of impressed, which impresses me. Wagner James Au seems not too impressed, but I'm not sure he's right that kids are dying for Habbo-style retro 2.5D graphics. He has a point about the downloaded client, but that hasn't held Maple Story back -- tweens will probably cross the install hurdle.
So my first impression, which is based entirely on the launch video below, is that this is pretty big. By giving FREE title credit, they're billing that they're not billing, which targets the zillions of kids now on Runescape, WebKinz, Maple Story, and Club Penguin.
But more importantly, I watch this video and I think: "Hey, isn't that Goldshire? Haven't I seen that guy before in IMVU, There, and Home? Is that a Nintendog? Aren't those Pokemon cards? MarioKart?" It is clear that SOE has done its kids media business homework really well -- as Scott puts it, tweens are "bracketed with laser-beam accuracy". Free Realms taps into the appeal of many of the choicest bits of the most popular properties out there for the demographic. They seem to be rolled together into a shiny integrated package.
Of course, one can't judge a virtual world by its cover, which I why I'd like to hear your reactions. Does it grind? Is it buggy? Does it feel coherent? Does the micro-payment model seem to work? But something about this video reminds me of seeing the first screenshots of World of Warcraft -- probably because they looked a lot like this. This is free, though.
Update: Good thoughts from Rocks, Paper, Shotgun ("all things to all children") More links to thoughtful analysis would be great.
We've been talking about TOS/EULAs for quite a long time here at Terra Nova. Here's a fairly obvious theory about these agreements, borrowed from Jeremy Bentham's felicfic calculus:
This post is a plug for an article that I’ve recently completed with my colleague Michael Carrier at Rutgers-Camden. The article is here. It is very short (for a law review article — 36 pages) and is our best effort to decisively end to the doctrine of “cyberproperty,” a.k.a. “cybertrespass,” a.k.a. the Internet variant of trespass to chattel doctrine.
Though this article doesn't explicitly mention it, cyberproperty doctrine has some interesting connections with virtual property and virtual worlds -- below I'll explain what cyberproperty is and how it relates to the concept of virtual property.
It's April 1st, but this is legit.
It's a hearing of the Energy and Commerce subcommittee. See this witness list and there's an MP3 of the proceedings now that can be found here. I'll refrain from comments until I've listened to all of this, but the opening statements of the Congressfolk were, to say the least, interesting.
Update: Video, audio, and prepared statements now archived here. Some news reports now available here. And one initial thought: apart from the opening remarks, this was mostly a hearing about Second Life. The speakers other than Rosedale talked primarily about Second Life and UGC worlds.
Update 2: On listening to testimony and further reflection, in lieu of commenting, I think I'll just point to Lum's reaction. I'm really not sure I have much to say about this event myself. Still, it is the first Congressional hearing on virtual worlds. I wonder what the first hearing on airplanes was like?
Update 3: Ok, my last comment on this, in reply to Raph's thoughts. If you can get past 1) the opening remarks, 2) the promotional video for Second Life, and 3) the fact that everyone at the hearing seemed to think that Second Life was synonymous with virtual worlds (made convenient by the fact that the other witnesses had major investments or involvements in Second Life), then you'll find the Q&A (starting at 51:20) has some very interesting stuff. Some of it shows the legislators being perceptive. Some of it shows the legislators and witnesses being not so perceptive. But if you're interested in the regulation of virtual worlds, it's worth a listen.
Did anyone see the MMORPG documentary Second Skin at SXSW?
I'm curious because the story from the official weblog seems to be that gamers are wildly enthusiastic about the film. The Escapist says: "gamers walk away feeling like they had seen seen their life story, with
slick editing, a peppy soundtrack, and the seductive polish of an Apple
commercial." On the other hand, this opinion at Gamasutra says: "As the lights dimmed, I was excited to explore how interactive media is
changing our experience of ourselves. But instead, I just wound up
feeling sorry for the losers playing World of Warcraft." Eric Zimmerman's comment (scroll down on that link) seems to accord with that: "I was distressed by a film that seemed to be a parade of gross stereotypes, most of which were clearly negative."
Who is right?
As part of the preparation for the book on law and virtual worlds that I'm writing, I've been trying to make a comprehensive list of published law review articles and student notes that focus on the intersection of law and virtual worlds.
Just in case readers are interested, the current version is attached below. If I'm missing something, please let me know in the comments or by email.
As you'll see, the rate of publications has been increasing, with the majority of the publications coming out in the past couple of years.
My friend Orin Kerr is a leading expert in the area of cybercrime and the author of the Computer Crime Law casebook, the first legal casebook in this area. He is also a blogger at the Volokh Conspiracy, one of the most-visited legal weblogs. Orin has just posted a draft to SSRN of his forthcoming essay, Criminal Law in Virtual Worlds. It's quite timely, given the ongoing discussion of Arno's recent post. Here's the abstract:
About a year and a half ago, I pointed out some commentary on trademark law in virtual worlds. In the past year, there have been many developments on this front, including the Eros lawsuits in Second Life and more attention from legal practitioners (see this from WIPO). So, when I was recently invited by the Santa Clara Computer and High Technology Law Journal to write about user-generated content and virtual worlds for a Symposium, I decided to write a short overview of the topic of Virtual Trademarks with Candy Dougherty.
You can find the current draft here on SSRN. The abstract reads:
In this article, we discuss how trademark law might apply to virtual worlds and virtual economies. In Part I, we consider how trademark infringement in virtual worlds resembles and differs from trademark infringement in other media. In Part II, we look at the various business models of contemporary virtual worlds and how commerce takes place within them. In Part III, we consider the circumstances where trademark infringement may occur in virtual worlds by discussing questions of use, confusion, dilution and fair use. In Part IV, we examine the issue of contributory trademark infringement.
We'd like to welcome two guests to Terra Nova for this month of February: Andrew Jinman and Arno Lodder. We're looking forward to their posts and some interesting discussions. Biographical information & intros from both Andrew and Arno follow below the fold...
Below are some recent mainstream media stories on virtual worlds for those who might have missed them. Thoughts, comments, and links to other things welcome, as always.
Before that, though, if you should happen to be in Santa Clara County on Friday (the Computer History Museum in Mountain View, specifically), I'll be there as part of a panel talking about how trademark law should work in virtual worlds. See this page. Much more interesting, though, are the other folks who will be speaking, such as Richard Stallman, Alex Kozinski, Marty Roberts (GC of Linden Lab), Chris Kelly (Chief Privacy officer of Facebook), Zahavah Levine (Chief Counsel of YouTube), and a whole bunch of other people rather fancier than myself. Apparently, you can attend for free, although they encourage you to donate $10 to pay for cheese and such.
Now onto the news...
About ten years ago, when I was wandering around the library at the University of Virgina looking for something that would teach me about the shape of community online, I found My Tiny Life. I pulled it off the shelf and started with the first few pages in which the author confronts a RL server in Palo Alto that happens to contain LambdaMOO.
It's a wonderful little depiction of a person trying to reconcile a vibrant and rich virtual world with the "silent, bone-white" machine that houses it. After reading those pages, I was hooked. I had found the kind of writing and subject that made me sit down on the floor right next to the bookshelf -- I didn't want to expend the time or energy to find a table. I wasn't the only person affected this way by reading My Tiny Life. E.g. Larry Lessig's blurb on the back cover says: "Dibbell's story is why I teach cyberlaw."
Well, the main point of this post is that Julian has made his wonderful book available as a free download. You can get it here, in a very spiffy PDF file. The Web is now a richer place.
The secondary note is that Julian would like to make MTL even freer. Yet he hasn't managed that trick yet because apparently there's a little problem with the phones at HarperCollins UK. Explanation of that here (and that page also includes his reasons for wanting to release the book for free).
Amazon.com has had, for about a year, a beta feature/forum called Askville.com. According to the web site:
What is Askville?
Askville is a place where you can share and discuss knowledge with other people by asking and answering questions on any topic. It’s a fun place to meet others with similar interests to you and a place where you can share what you know.
An online Q&A community is not exactly a new idea. There's the defunct Google Answers and the non-defunct Yahoo Answers. And see USENET, that virtual community where netizens still share and discuss knowledge, ask and answer questions, and all that good stuff.
What's intriguing about Askville is not the substance of the exchange, but the incentive structure they have wrapped around it. There are experience points and Quest gold that can be earned by answering questions. For instance, if you look at the charts on that FAQ page, you'll see that in order to be a level 4 user on Askville, and get a 20 gold payout bonus, you'll need to have 1,500-2,999 experience points. The real innovation here is that Amazon is apparently targeting all the Gygaxians out there. Is that a good idea? Is it a fun idea?
Q. I thought my thoughtful, sensitive, conscientious, kind, funny, handsome son would grow up to be successful, happy and self-sufficient but he's 20 now, he's passed only one or two classes in his two years at community college and he quits every part-time job he gets.
He is addicted, I think, to online gaming. He says he isn't interested in anything but playing his game -- a game, I'm ashamed to say, I gave him years ago -- and only wants to work for the maker of the game or the gaming industry...
One of our banner submitters, Tripp Robbins, let us know he was eager to get word out about a project he is working on to use virtual worlds as an educational tool. The website of the project is here and I asked Tripp if he could write a short summary of what he is up to for the blog so that people can have a chance to provide input. So that follows below. Thanks, Tripp!
Summary of the NEW NEXUS PROJECT for Terra Nova
After spending a lot of time in various virtual worlds/games/simulation, the idea of using a VW for education seemed powerful. I spent the last 18 months or so doing research on “what’s out there” (and I’m sure I missed a lot). After a great seminar on “Using Videogames in Education” at Stanford University with James Gee as the key presenter (and others from UWisconsin and Stanford) last summer, I came away feeling like what was needed is a tool kit for educators to create VW content. That led to the creation of the New Nexus project.
Back to the snowy trees (we used this one a couple years ago). I've added a snowish backdrop too.
October 24, 2008:
This kind of abstracty one is just me goofing around with Corel Painter and the little Wacom tablet. The prior banner we've had this fall (with the nice Tudor houses) was from Rory Starks of the Arden team -- the image can be found lower down in this post.
Thanks to Mark Terrano for a new springy banner!
As you might have noticed, we've emerged somewhat from winter and I've reinstated the banner from Chris Dodds. At some point, I might switch us to something more emphatically "springy," but I have yet to see the flowers emerging with any real force here in Philadelphia...
Thanks to everyone who sent in stuff. Though it was a close race, Richard Page's submission came in with the most votes. TN is now settled in for a long winter's blog.
This call for papers (received via Vili) is of interest, given our frequent discussions about the magic circle here.
Breaking the Magic Circle
Call for Papers: Game Studies Seminar, Tampere 10-11 April, 2008
One of the classic theories of games and play was presented by Johan Huizinga in his work Homo Ludens (orig. from 1938). Huizinga wrote about the free and voluntary nature of play, how it is "an activity connected with no material interest" and how it "proceeds within its own proper boundaries of time and space", involving and absorbing players utterly into a separate world set off from the "ordinary" life, while being created and maintained by communities of players.
So Tabula Rasa is released today, after many years of rumor and speculation. What is written on the clean slate? Wired's Susan Arendt claims that it reinvents the MMO to court casual gamers, the point being that you can get into hectic tactical combat quickly. Seth Schiesel of the New York Times offers some interesting quotes from Richard Garriott that make a few more pitches about the game:
As many kudos as I would like to give World of Warcraft, it’s basically a remake of EverQuest, just incredibly polished and refined,” he said. “There are harbingers of failure in that model. Everyone in these games is obsessed with the concept of how much damage-per-second they are inflicting and maximizing their D.P.S. When you do that, you are no longer playing a role; you are playing an inventory-management game... With Tabula Rasa we wanted the player to spend as much time as possible actually looking at the environment and what they’re shooting at.
I'm currently re-reading a bit of Jesper Juul's book, Half-Real. I should say at the outset that I haved always enjoyed Juul's general approach to videogame studies. His work is highly accessible, innovative, thoughtful, and centered on concrete (and popular) examples. (He also includes lots of screenshots, which is good.) Juul takes what might be called a "grassroots" approach to game studies, not bringing heavy disciplinary baggage to colonize the area, but instead trying to build a formal theory of games from the ground up. He takes his lead primarily from game and culture theorists like Huizinga, Caillois, Crawford and Sutton-Smith rather than from literary theory or media studies.
But I don't want to review Half-Real here -- I just want to share a passage that made me wonder a bit about the differences between MMORPGs and other games. The question is: how do players set the balance in MMORPGs between world immersion and game/rule objectives?
We're very excited to welcome Nicolas Nova to Terra Nova as a guest author for the month of October. Nicolas is a cognitive scientist by training and works as a research scientist at the Media and Design Lab (Swiss Institute of Technology, EPFL) in Lausanne, Switzerland and as a user experience and foresight researcher for IT and video-game companies.
It looks like Google might really be planning an avatar space. We noted vague fuzzy hints of something a year ago, but it now seems Arizona State is doing student sign-ups for a prototype test of an avatar/game/social network for a "major internet company" which everyone seems to think is the G-borg. Google isn't talking, no real details are out there that I found, and the beta isn't live yet, but... the cutesy little graphic on the ASU page asks:
"Are you into 3D modeling, videogaming, etc? Do you have a virtual avatar? If so, click here!"
The New York Times ran a pretty standard Second Life "people are buying and selling virtual stuff and working in virtual jobs" article yesterday. Nothing new, really. I only mention it here because Julian, Robert, and Nick get quoted -- so good for you guys! :-)
Lately I've been doing some amateur dabbling in theories of space. One interesting book I'm reading is Kevin Lynch's The Image of the City. According to the Lynch, our cities should not be understood as facts about arrangements of bricks and metal, but as a shared social constructs, collectively read and navigated by inhabitants. In the minds of their residents, cities are mentally modeled around important landmarks that function as connecting passages and allow the creation of heuristically functional (though perhaps factually faulty) cognitive maps. (De Certeau would add that in daily life, we read and write cities as we traverse them, drawing and inscribing new meaning with each navigation.)
Continuing some themes from several prior posts, we find John Tierney of the New York Times presenting Nick Bostrom's argument that life is just a sim created by a higher being. Link. Tierney says he's convinced and adds:
[I]f owners of the computers were anything like the millions of people immersed in virtual worlds like Second Life, SimCity and World of Warcraft, they’d be running simulations just to get a chance to control history — or maybe give themselves virtual roles as Cleopatra or Napoleon.